2025 Annual IT Audit and Exam Issues: Insights and Multi-Year Trends from NETBankAudit

As the regulatory and threat landscape for financial institutions continues to evolve, understanding the latest IT audit and exam issues is essential for compliance professionals. NETBankAudit’s 2025 analysis, based on over 170 financial institutions, offers a detailed look at the most significant IT and compliance challenges facing the industry. This year’s findings are presented alongside multi-year trends, providing context for how examiner focus and institutional risk profiles have shifted since 2023.

NETBankAudit experts have over 25 years of experience in IT audit and regulatory compliance. If you have questions after reading this guide, please reach out to our team.

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2025 NETBankAudit Audit Volume

In 2025, NETBankAudit performed 347 audit engagements, with 82% focused on IT/operations, 12% on BSA Compliance and BSA MIS, and 6% on Compliance/Internal Audit. Additionally, 1,074 standalone technical assessments were conducted, including internal and external network vulnerability assessments, penetration tests, system and process assessments, model validations, and social engineering tests. Over 95% of IT audit engagements included some form of vulnerability assessment and testing, reflecting the ongoing regulatory emphasis on cyber resilience and operational risk management.

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Metric	2023	2024	2025
Total Audit Engagements	265	277	347
IT / Operations Audits	80%	80%	82%
BSA Compliance & BSA MIS	13%	13%	12%
Compliance / Internal Audit	7%	7%	6%
Standalone Technical Assessments	793	827	1,074
IT Audits with Vulnerability Testing	95%+	95%+	95%+

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2025 Regulatory Exam Issues: Key Findings and Year-Over-Year Comparison

NETBankAudit’s annual survey of examination issues provides a unique window into the priorities of state and federal regulators (includes FDIC, NCUA, FRB, OCC and State/DIFS). The 2025 survey, based on approximately 170 financial institutions, highlights the most frequently cited exam issues shifts compared to previous years.

Top Six Regulatory Exam Issues in 2025

In 2025, the most commonly reported exam issues were:

Cybersecurity (19%)
IT Governance (9%)
Vendor Management (12%)
Business Continuity (10%)
Regulatory Compliance (10%)
User Access (5%)

Cybersecurity remains the leading concern, consistent with both 2024 and 2023. However, Vendor Management has risen to the third spot, reflecting increased examiner focus on third-party and cloud provider risks.

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Regulatory Exam Issue	2023	2024	2025
Cybersecurity	19%	16%	19%
IT Governance	16%	11%	9%
Business Continuity	10%	10%	10%
Vendor Management	7%	10%	12%
Regulatory Compliance	<1%	7%	10%
Risk Assessment	7%	7%	8%
User Access Controls	8%	7%	5%

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Multi-Year Trends: 2023–2025

Comparing the 2025 results to prior years reveals several notable trends:

Cybersecurity has consistently been the top exam issue, though its share has fluctuated: 19% in 2023, 16% in 2024, and 19% in 2025.
IT Governance, while still a top concern, has seen a slight decrease in relative frequency, from 16% in 2023 to 11% in 2024 and 9% in 2025.
Vendor Management’s prominence has grown, with 12% in 2025 compared to 10% in 2024 and 7% in 2023, driven by regulatory attention to outsourcing and cloud risk.
Business Continuity and Regulatory Compliance have remained steady, each accounting for around 10% of issues in recent years.
User Access, while still significant, has declined slightly as institutions have improved controls in response to examiner feedback.

NETBankAudit’s Top Identiﬁed IT Audit Control Issues in 2025

NETBankAudit’s risk-based IT audit methodology, grounded in the COBIT framework, enables a detailed evaluation of 22 control objectives across IT governance, management, operations, and security. The 2025 audit data, drawn from approximately 170 financial institutions, highlights the most prevalent control weaknesses and provides a basis for benchmarking institutional performance.

Top Five Audit Issues in 2025

The most frequently identified audit issues this year were:

Network Security (24.31%)
Change Management & Problem Management (11.90%)
Hardware & Software Controls (8.85%)
Business Continuity Management (8.13%)
Outsourcing and Vendor Management Controls (5.88%)

Network Security continues to dominate, with its share rising from 18% in 2023 and 26% in 2024 to over 24% in 2025. Change Management & Problem Management also increased, reflecting ongoing challenges with patching, system updates, and incident handling. Hardware & Software Controls, while still a major issue, have seen gradual improvement as institutions mature their asset management practices. Business Continuity Management and Vendor Management round out the top five, underscoring the importance of resilience and third-party oversight in today’s risk environment.

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Control Area (COBIT Model)	2023 %	2024 %	2025 %
Network Security	18%	26%	24%
Change Management & Problem Management	9%	12%	12%
Hardware & Software Controls	13%	10%	9%
Business Continuity Management	7%	7%	8%
Outsourcing & Vendor Management	4%	6%	6%
User Access Controls	8%	7%	5%
Logical Access Controls	4%	4%	5%
Risk Assessment	5%	4%	4%
Training & Awareness	4%	3%	3%
Information Security & Cybersecurity Programs	4%	1%	3%
Incident Prevention & Response	2%	3%	3%
Policies & Procedures	4%	1%	2%
Project Management	1%	2%	2%
Logging & Monitoring Controls	2%	2%	2%
IT Governance Framework	3%	2%	2%
Compliance Monitoring	3%	1%	2%
Strategic Planning, Implementation & Transparency	3%	1%	4%
Data Assurance	1%	2%	1%
System Design, Availability & Capacity	1%	1%	1%
Input / Output (End-to-End) Controls	2%	1%	1%
Physical Controls	2%	2%	2%
Organizational Structure & Provisioning	<1%	1%	1%

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Year-Over-Year Audit Issue Comparison

Looking back, the top five audit issues have remained largely consistent since 2023, though their relative proportions have shifted. The rise in Change Management & Problem Management findings in 2025 signals increased examiner and auditor scrutiny of IT change controls, software lifecycle management, and incident response processes. Vendor Management’s continued presence in the top five reflects the growing complexity of third-party relationships and the need for robust oversight mechanisms.

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Hot Topics, Concerns, and Emerging Trends for 2025

Each year, NETBankAudit identifies emerging risks and persistent challenges that compliance professionals should prioritize. The 2025 hot topics reflect both regulatory developments and evolving threat vectors, with several new areas of focus compared to previous years.

Key Areas of Concern in 2025

Institutions should pay particular attention to the following:

IT Governance: Segregation of duties between CTO and ISO, management’s authority to accept risks, and formal management of risk exceptions.
Patch Management: Addressing end-of-life operating systems and software, and ensuring timely patch deployment.
Baseline Configuration Reviews: Establishing and regularly reviewing secure configurations for all systems.
Active Directory Multifactor Authentication: Implementing MFA for directory services to mitigate credential compromise risks.
Artificial Intelligence: Developing AI policies, conducting risk assessments, and addressing AI-driven social engineering threats.
Cybersecurity: Ransomware assessment and testing, restricting outbound ports and Tor network access, upgrading SMB signing, and addressing out-of-date encryption protocols. Application whitelisting and cyber insurance coverage alignment are also critical.
Business Continuity: Enhancing test plans, tracking after-action issues, and ensuring BCPs are current and actionable.
Data Assurance: Improving backup job success rates, retention policies, and regular testing of data restoration processes.
Physical Security: Addressing ATM/ITM jackpotting attacks and reviewing physical access controls.
Logging and Monitoring: Implementing network log retention standards and advanced monitoring solutions such as Carbon Black.
User Access Management: Managing service account passwords and eliminating default credentials on network devices.
Incident Response: Developing cyber-scenario response plans, clarifying notification requirements, and improving incident alerting mechanisms.
Vendor Management: Clearly defining responsibilities between the institution and vendors, especially with cloud providers, and ensuring vendor parameters are aligned with bank-controlled settings.

Many of these topics, such as AI risk management and advanced ransomware testing, have grown in importance since 2024, reflecting both regulatory guidance and real-world incident trends. The focus on cloud provider oversight and cyber insurance policy alignment is also increasing, as institutions expand their reliance on third-party technology solutions.

Action Items for Compliance Professionals

Based on the 2025 findings and multi-year trends, compliance professionals should:

Review and update IT governance structures, ensuring clear segregation of duties and formal risk acceptance processes.
Strengthen patch management and configuration review procedures to address emerging vulnerabilities and regulatory expectations.
Implement and test multifactor authentication for all critical systems, especially directory services and remote access points.
Develop and maintain AI risk management frameworks, including policies, risk assessments, and controls for AI-driven threats.
Enhance business continuity and incident response plans, with a focus on actionable test results and after-action tracking.
Expand vendor management programs to address cloud provider risks and clarify roles and responsibilities in service agreements.

Institutions that proactively address these areas will be better positioned to meet examiner expectations and reduce operational risk.

How NETBankAudit Can Help Your Institution

NETBankAudit serves over 850 financial institutions across 42 states, providing risk-based IT general controls auditing, vulnerability assessments, penetration testing, social engineering testing, and specialized transactional audits. Our certified, senior-level auditors bring deep expertise in IT engineering, regulatory compliance, and financial services operations. We deliver actionable insights that help institutions not only meet regulatory requirements but also strengthen their overall security posture and operational efficiency.

If your institution is preparing for an exam, addressing new regulatory guidance, or seeking to improve its IT risk management program, contact NETBankAudit to learn how our services can support your goals and secure your digital future.

 
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2025 Annual IT Audit and Exam Issues: Insights and Multi-Year Trends from NETBankAudit

2025 NETBankAudit Audit Volume